Vt. Stat. Ann. » Title 28 Chapter 5
Vermont Statutes Annotated

Vt. Stat. Ann. tit. 28, § 301 (2026)

✓ current as of May 2026
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Subchapter 003 : REVOCATION OF PROBATION

(Cite as: 28 V.S.A. § 301)
Notes of Decisions
Cited in 22 cases (4 in the last 5 years), 1988–2025 · leading case: State v. Breer, 160 A.3d 318 (Vt. 2016).
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State v. Breer, 160 A.3d 318 (Vt. 2016). · cites it 5× “§ 7553, and also because he was charged with violations of probation, 28 V.S.A. § 301(4). The trial court then made specific findings that the evidence of guilt on the criminal charges was great under § 7553.”
State v. Malik A. Pratt, 2017 VT 9 (Vt. 2017). “§ 7554(a)(1)(A) (condition applicable only to offenses that are not nonviolent as defined in 28 V.S.A. § 301 ). 7 We acknowledge that the state cannot incarcerate people simply because they cannot pay a fine or judgment.”
In re Mark Jankowski, 2016 VT 112 (Vt. 2016). · cites it 2× “28 V.S.A. § 301; id. § 302(a). This is the violation stage of the proceeding.”
State v. Breer, 2014 VT 132 (Vt. 2014). · cites it 5× “28 V.S.A. § 301(4). ¶ 3. Defendant was held without bail pending trial because he is charged with several offenses punishable by life imprisonment, 13 V.”
State v. William Edward Bailey, 2017 VT 18 (Vt. 2017). · cites it 2× “It considered the "nature and circumstances" of the manslaughter charge, agreeing with defendant that "there's no evidence that it was the defendant's intent to kill the decedent" but also stating that it was a "depraved act, to put a gun to somebody's head and pull the trigger.”
State v. Campbell, 2014 VT 123 (Vt. 2014). · cites it 2× “28 V.S.A. § 301(4). Included in the listed crimes is “violation of abuse prevention order as defined in section 1030 of [title 13].”
State v. Barrows, 776 A.2d 431 (Vt. 2001). “On appeal, defendant acknowledges that as a probationer charged with violation of probation he has no right to bail or release pursuant to 28 V.S.A. § 301(4) (“There shall be no right to bail or release.”
State v. Murray, 617 A.2d 135 (Vt. 1992). “” The power of the court or probation officer to arrest or summons a probationer to answer charges that probation should be revoked is limited to the period “before the discharge of the probationer or the termination of the period of probation.”
State v. Blow, 2015 VT 143 (Vt. 2015). “§ 7554 and 28 V.S.A. §301(4) (allowing detention pending a probation hearing).”
State of Vermont v. Jonathan Houle, 2015 VT 29 (Vt. 2013). · cites it 2× “The State urges us to decide that petitioner, as a probationer convicted of a violent crime, has neither a constitutional nor a statutory right to bail, see 28 V.S.A. § 301(4), and that, therefore, he should have no bail review.”
State v. White, 549 A.2d 1069 (Vt. 1988). “In like manner, the statutory section dealing with revocation of probation provides that a probationer may be summoned or arrested “[a]t any time before the discharge of the probationer or the termination of the period of probation .”
State v. Ellis, 542 A.2d 279 (Vt. 1988). “28 V.S.A. § 301 states that: “[a]t any time before the discharge of the probationer or the termination of the period of probation .”
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— Vt. Stat. Ann. tit. 28, § 301(4) — 16 cases
State v. Breer, 160 A.3d 318 (Vt. 2016). “§ 7553, and also because he was charged with violations of probation, 28 V.S.A. § 301(4). The trial court then made specific findings that the evidence of guilt on the criminal charges was great under § 7553.”
State v. Breer, 2014 VT 132 (Vt. 2014). “28 V.S.A. § 301(4). ¶ 3. Defendant was held without bail pending trial because he is charged with several offenses punishable by life imprisonment, 13 V.”
State v. Campbell, 2014 VT 123 (Vt. 2014). “28 V.S.A. § 301(4). Included in the listed crimes is “violation of abuse prevention order as defined in section 1030 of [title 13].”
State v. Barrows, 776 A.2d 431 (Vt. 2001). “On appeal, defendant acknowledges that as a probationer charged with violation of probation he has no right to bail or release pursuant to 28 V.S.A. § 301(4) (“There shall be no right to bail or release.”
State v. Blow, 2015 VT 143 (Vt. 2015). “§ 7554 and 28 V.S.A. §301(4) (allowing detention pending a probation hearing).”
— Vt. Stat. Ann. tit. 28, § 301(4)(A) — 1 case
State v. Patricia Kane, 2016 VT 121 (Vt. 2016).
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